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Typically, petitioner made two or three deposits per week
into the business account. Business account deposits made during
the years in issue are summarized below:
Year Check Deposits Cash Deposits Total
1993 $11,604.36 $12,175.06 $23,779.42
1994 19,210.40 9,962.16 29,172.56
1995 16,771.64 12,680.29 29,451.93
Total $47,586.40 $34,817.51 $82,403.91
Deposits into petitioner’s other bank accounts are
summarized as follows:
Year Check Deposits Cash Deposits Total
1993 $74.16 $52,204.35 $52,278.51
1994 300.00 44,401.00 44,401.00
1995 --- 39,004.00 39,004.00
Total $374.16 $135,609.35 $135,683.51
Before the years in issue, petitioner’s investments were
generally limited to real estate. During this time, he
purchased, rented, and sold several houses. In 1993, petitioner
began investing in securities. In January 1993, petitioner
purchased three U.S. Savings Bonds, each with a face value of
$10,000. Between July 1993 and October 1995, petitioner invested
approximately $158,000 in various mutual funds. Thereafter, it
appears that petitioner’s interest in investing in securities
faded rapidly. On December 5, 1995, petitioner redeemed mutual
fund shares with a net asset value of $119,187.30. On December
20, 1995, petitioner purchased real property for approximately
$83,000.
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